Pullen Investment Management LLC

Item 5 – Fees and Compensation

In addition to the information provided in Item 4 – Advisory Business, this section provides additional
details regarding our firm’s services along with descriptions of each service’s fees and compensation
arrangements. It should be noted that lower fees for comparable service may be available from other
sources. The exact fees and other terms will be outlined in the agreement between you and PIM.

Asset Management Services

Fees charged for our asset management services are charged based on a percentage of assets under
management. Fees may be either billed in advance (at the start of the billing period) or in arrears (at the
end of the billing period) at the discretion of the advisor. Fees are billed on a quarterly calendar basis and
calculated based on the fair market value of your account as of the last business day of the previous
billing period. Fees are prorated (based on the number of days service is provided during the initial billing
period) for your account opened at any time other than the beginning of the billing period. If asset
management services are commenced in the middle of a billing period, the prorated fee for the initial
billing period is calculated and billed in advance at the account opening.

The asset management services continue in effect until terminated by either party (i.e., PIM or you) by
providing written notice of termination to the other party. Any prepaid, unearned fees will be promptly
refunded by PIM to you. Fee refunds will be determined on a pro rata basis using the number of days
services are actually provided during the final period.

Fees charged for our asset management services are negotiable based on the type of client, the
complexity of the client's situation, the investment strategy utilized, the investment advisor representative
managing the account, the composition of the client's account (i.e., equities versus ETFs), the potential
for additional account deposits, the relationship of the client with the investment adviser representative,
and the total amount of assets under management for the client.

The annual fee for asset management services will be up to a maximum of 1.00% per annum on all
assets under management.

For our Small Cap strategy only, we offer a Founder’s Shares fee structure of 0.30% annually for clients
with at least a $5 million allocation. The Founder’s Shares offer will be in place until the Small Cap
strategy composite reaches $100 million in total assets. Above that level, Founder’s Shares clients will
maintain their 0.30% annual rate into perpetuity. New clients with at least a $5 million allocation to our
Small Cap strategy will be managed at a rate of 0.75% annually. The asset management fees for our
other investment strategies will be based upon the firm’s standard fee schedule (above) and can be
negotiated with each client.

The actual fee to be charged will be specified in your client agreement.

Pullen Investment Management, LLC                  Page 10                        Form ADV Part 2A Firm Brochure

There is a minimum account size of $300,000 and a minimum annual fee of $2,100 these minimum
requirements may be waived at the discretion of the advisor.

PIM believes that its annual fee is reasonable in relation to: (1) services provided and (2) the fees
charged by other investment advisers offering similar services/programs. However, our annual
investment advisory fee may be higher than that charged by other investment advisers offering similar
services/programs. In addition to our compensation, you can also incur charges imposed at the
investment level (e.g., advisory fees and other internal expenses).

The investment advisory fees will be deducted from your account and paid directly to our firm by the
qualified custodian(s) of your account. You will authorize the qualified custodian(s) of your account to
deduct fees from your account and pay such fees directly to our firm. Our firm will send you a billing
statement prior to time that fee deduction instruction is sent to the qualified custodian(s) of your account.
The billing statement will detail the formula used to calculate the fee, the assets under management and
the time period covered. See Item 15 – Custody for more details.

You should review your account statements received from the qualified custodian(s) and verify that
appropriate investment advisory fees are being deducted. The qualified custodian(s) will not verify the
accuracy of the investment advisory fees deducted.

Brokerage expenses and/or transaction fees charged by the qualified custodian are billed directly to you
by the qualified custodian. PIM does not receive any portion of such commissions or fees from you or the
qualified custodian. In addition, you will incur certain charges imposed by third parties other than PIM in
connection with investments made through your account including, but not limited to IRA and qualified
retirement plan fees, and charges imposed by the qualified custodian(s) of your account. Management
fees charged by PIM are separate and distinct from the fees and expenses charged by any third party.

Fee waivers or discounts may be offered to family members and friends of associated persons of PIM
which are not available to Clients.

Financial Planning & Consulting Services

Fees charged for my financial planning and consulting services are negotiable based upon the type of
client, the services requested, the complexity of the client’s situation, the composition of the client’s account,
and the relationship of the client and the investment adviser representative. The following are the fee
arrangements available for financial planning and consulting services offered by PIM.

                                    Fees for Financial Planning Services

PIM provides financial planning and consulting services under a fixed fee arrangement. A fixed fee of up
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Item 7 – Types of Clients

PIM generally provides investment advice to the following types of clients:

    •    Individuals
    •    High net worth individuals
    •    Retirement Plans
    •    Trusts
    •    Estates
    •    Small Businesses and Corporations

You are required to execute a written agreement with PIM specifying the particular advisory services in
order to establish a client arrangement with PIM.

Minimum Investment Amounts Required

PIM typically requires a minimum of $300,000.00 in order to open an account and a minimum annual fee
of $2,100.00. To reach these account minimums, clients can aggregate all household accounts.
Exceptions may be granted to these minimums at the discretion of the advisor. The firm’s Small Cap
Strategy has a unique fee schedule based upon the account minimum balances, Please see Item 5-
Fees and Compensation for more specific information.